Introductory Statement
Modern Slavery[1] is a grave violation of human rights that continues to persist globally. This policy outlines Cornwalls’ measures and strategies to combat Modern Slavery and protect the rights of vulnerable individuals.
Cornwalls is committed to upholding human rights including fair labour practices and safeguarding workers within its operations and supply chains, protecting them from exploitation and Modern Slavery.
This statement affirms our support of global initiatives aimed at promoting human rights and social progress. We also adhere to essential international laws, principles, and standards, such as the United Nations (UN) Declaration on Human Rights, International Labour Organisation Conventions, and the Modern Slavery Act 2018 (Cth), with a goal of eradicating Modern Slavery in all its forms.
We would like to acknowledge the traditional custodians of the lands on which we live and work. We would like to pay respect to the Elders of these lands, both past and present, and extend that respect to all Aboriginal and Torres Strait Islander Peoples and First Nation Peoples globally.
Modern Slavery Statement
As providers of legal services, we uphold the rule of law, respect human rights and promote the mitigation of the risk of Modern Slavery.
Through this statement, we affirm our commitment to never engage in forced, compulsory, trafficked, or child labour within our organisation and to take reasonable steps to confirm that those in our supply chains do likewise. If we become aware of inappropriate labour practices within our supply chains, we will report them to the appropriate authorities.
Structure, operations and supply chains
We have offices in Melbourne, Sydney and Brisbane.
Cornwalls provides legal and advisory services to clients. Cornwalls has a number of associated entities and, through our Melbourne office, Associations or alliances with other organisations such as Andersen Global.
Our workforce primarily consists of legal professionals, with embedded business services, technology, finance, legal operations, payroll, administrative, and HR teams providing essential support. The majority of our workforce is employed on an ongoing basis. We also engage a limited number of contractors, casual workers, and external consultants to meet specific needs and address specialised requirements.
Our supplier base encompasses various industries and services. For example, suppliers of IT and communications equipment and services, property management services, office cleaning, facilities management services, transportation services (including airlines and couriers), marketing suppliers (including merchandise and conference providers), office equipment suppliers, and various professional services providers such as auditors, accountants, consultants, legal counsel, foreign law firms (e.g. in jurisdictions where we do not have local offices), banks, insurers, recruitment agencies, education and training service providers.
While the majority of our suppliers are based in Australia.
Modern Slavery risks in our operations and supply chains
Our operations
We assess risks associated with Modern Slavery for the purpose of ensuring ethical practices throughout our organisation.
We have determined that the overall risk of Modern Slavery in our operations remains low. This conclusion is supported by the nature of the legal services sector, the lower prevalence of Modern Slavery in Australia, and the robust workplace relations processes we have.
Our recruitment practices follow strict protocols to safeguard against any potential exploitation.
We verify qualifications, conduct thorough reference checks on prior experience, and verify the right to work in our country. Additionally, we maintain ongoing monitoring of our workforce to ensure adequate compensation and prevent excessive work patterns.
Supply chains
We uphold our commitment to ethical practices and human rights by actively assessing the potential risks of Modern Slavery within our supply chain.
Our assessment at the time of this statement is that the likelihood of directly causing or contributing to Modern Slavery in our procurement of goods or services is minimal.
We monitor and evaluate our supply chain profile, ensuring our understanding of potential risks remains up to date.
To the extent we are able to do so, Modern Slavery remains unwavering, and we will actively collaborate with suppliers to promote responsible practices and mitigate risks.
Categories of Modern Slavery risks
| Generally known Modern Slavery risks[2] | |
|---|---|
| IT equipment and software | The manufacturing of IT equipment has unfortunately been associated with instances of Modern Slavery. As a responsible organisation, we take this matter seriously and strive to uphold the highest standards of social responsibility and ethical sourcing. |
| Travel and accommodation | The travel and accommodation industry can be at risk of Modern Slavery due to its reliance on seasonal, temporary, and migrant workers in vulnerable conditions. The fragmented nature of the industry, with multiple sub-contractors and suppliers, may obscure exploitative practices. Robust vigilance and responsible sourcing are essential to address these risks. |
| Cleaning and laundry | The cleaning industry is identified as a high-risk sector for Modern Slavery, primarily due to the characteristics of its workforce and the inherent opacity in its operations. In this sector, qualifications are not always required, resulting in a predominantly low-skilled workforce with limited proficiency in the local language. These factors contribute to the heightened vulnerability of workers in the cleaning industry to Modern Slavery practices. |
| Hospitality and food services | Food-related supply chains are identified as having a high risk of Modern Slavery. This concern extends beyond supermarkets and suppliers, encompassing producers, distributors, and caterers. The complex and often global nature of food supply chains creates opportunities for exploitation, making it imperative for all stakeholders in the industry to be vigilant in addressing Modern Slavery risks. |
| Print and mail management | The print and mail management industry can be at risk of Modern Slavery due to the reliance on manual labour, often involving low-skilled workers in vulnerable positions. Outsourcing and complex supply chains may create opportunities for exploitation, making it crucial to proactively address and mitigate these risks. |
Due diligence process and steps taken to assess and manage Modern Slavery risk
As a provider of legal services, a purchaser of goods and services, and an employer, we uphold our responsibility under the UN Guiding Principles on Business and Human Rights.
We remain committed to identifying and addressing Modern Slavery risks across our operations, client services, and supply chain.
Our commitment to combating Modern Slavery in all its forms remains steadfast, and we are diligent in identifying any actual or potential risks within our business.
Our actions to assess and manage Modern Slavery risks during the Reporting Period include:
Monitoring reports
We are pleased to report that no reports of actual or suspected violations of our Modern Slavery Policy, or any concerns related to human rights, were received during this period.
Communication with our people
We reinforce our employees our firm’s commitment to respecting human rights within our operations and supply chain including by reminding our employees of the existence of this policy and how they access it.
Training
During each Reporting Period, we raise awareness about Modern Slavery including without the staff and clients. We also supply a copy of this policy to clients and potential clients upon request and assist clients with developing their own Modern Slavery policies.
Our existing policies and procedures, are actively operational during each Reporting Period,
reflecting our dedication to ethical practices.
During each Reporting Period, the actions taken by our business to assess and address our Modern Slavery risks relate to four key areas:
- procurement and supplier due diligence;
- governance and policy review;
- employment terms and conditions; and
- Modern Slavery education and awareness
Procurement and supplier due diligence
During each Reporting Period, where appropriate or that a risk of Modern Slavery is considered to possibly exist, we request our suppliers to confirm they maintain only practices which do not involve or have a tendency to lead to Modern Slavery and ask our contractors and suppliers to manage their risk of Modern Slavery within their businesses and supply chains.
In doing that, we conduct a desktop due diligence of our suppliers, by analysing their geographic location, sector or category, and publicly available market reputational information for. We have not as at the date of this policy, identifying any Modern Slavery in our supply lines.
Governance, policies and procedures
During each Reporting Period, Cornwalls conducts a Modern Slavery review of our governance, policies, and procedures. If such a review establishes that it would be appropriate to do so, this policy is republished.
Modern Slavery Policy
This policy underscores our stance against Modern Slavery and highlights our dedication to upholding ethical business practices. As part of our collective responsibility, all Cornwalls employees must refrain from any actions that could lead to a violation of this policy. They are also encouraged to recognise the significance of human rights and identify potential Modern Slavery risks. We encourage open communication, urging all employees to promptly report any concerns they may encounter.
Procurement policy and required conduct
Our policy is to only engage with suppliers who have no involvement in Modern Slavery and who do not participate in practices which might lead to it, including not being engaged in or associated with any form of human trafficking, exploitation, forced labour, or child labour.
Employees are directed to only deal with reputable suppliers who demonstrate a firm commitment to upholding legal and ethical obligations. By adhering to these criteria, we uphold our dedication to responsible sourcing and ethical business practices.
Representations to clients
We acknowledge our crucial role in our clients’ supply chain. When requested to respond to Modern Slavery inquiries in a client’s request for tender, we affirm our commitment to combating Modern Slavery and provide them with a copy of this policy.
Employment terms and conditions[3]
During each Reporting Period, we ensure that the sourcing of personnel through short-term contracts, labour hire arrangements, or foreign workers on international visas does not give rise to additional Modern Slavery risks for our business.
Looking forward, we plan
As part of the next steps in its commitment against Modern Slavery, Cornwalls aims to:
- Appoint a nominated person to support our Modern Slavery objectives;
- Centralise our processes throughout various officers to ensure a consistent approach;
- Emphasise particularly with our administrative staff involved in procurement, the need to keep our Modern Slavery objectives front of mind; and
- Review our progress and monitor any adverse developments within our supply chain.
Measuring the effectiveness of steps taken
During each Reporting Period, Cornwalls conduct a Modern Slavery review of our governance, policies, and procedures. To date no review has established any breaches of this policy measures.
Awareness of policy
We measure the extent to which new or updated policies and procedures the extent to which new or updated policies and procedures may be required in order to further our objectives towards the minimisation and elimination of Modern Slavery.
Senior management review
Senior management reviews compliance with this policy in each Reporting Period.
This statement is made on behalf of Cornwalls. Where we refer to “Cornwalls”, “we”, “us”, “our” or the “firm” in this statement, it means Cornwalls ABN 19 738 311 557 (a limited partnership), Cornwalls (QLD) ABN 18 604 548 601 (individual liability limited by a scheme approved under professional standards legislation) and Cornwalls (NSW) ABN 68 626 837 223 (liability limited by a scheme approved under professional standards legislation)
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[1] As defined in the Modern Slavery Act 2018 (Cth).
[2] The risks outlined in this table are general and do not relate to any actual instances of Modern Slavery in the supply chain of our first tier suppliers.
[3] As defined in the Modern Slavery Act 2018 (Cth).